Anti-Money Laundering (AML) Policy

Introduction

STARTUP SMART DEVELOPMENT LTD, registered in Hamchaku, Mutsamudu, Autonomous Island of Anjouan, Union of Comoros, operating under the international financial license with registration number 15559, trading under the brand name Perfect Money, is committed to complying with all applicable laws and regulations related to anti-money laundering (AML). This policy is designed to prevent the use of our services for money laundering and terrorism financing.

Objective

1. Ensuring compliance with the laws and regulations on anti-money laundering and terrorism financing.
2. Establishing procedures for identifying and reporting suspicious activity.
3. Protecting the reputation of Perfect Money and maintaining the trust of clients and partners.
4. Preventing the use of the company's products and services for illegal purposes.

Definitions

1. Money Laundering - the process of converting illegally obtained money into legal assets.
2. Terrorism Financing - providing or collecting funds used to support terrorist activities.
3. Suspicious Activity - any actions that may indicate an attempt to launder money or finance terrorism.

Responsibilities and Duties

1. Board of Directors and Senior Management:

• Responsible for developing and implementing the AML policy.
• Ensure the availability of necessary resources for implementing this policy.
• Periodically review and update the policy to ensure its relevance.

2. Employees:

• Must know and comply with AML policy requirements.
• Required to undergo AML training and participate in regular training sessions.
• Immediately report suspicious activity to the responsible person.

3. AML Officer:

• Appointed to coordinate all AML-related activities.
• Responsible for developing and implementing client identification and monitoring procedures.
• Timely reports suspicious activity to the appropriate authorities.

Anti-Money Laundering Procedures

1. Customer Identification (KYC):

• Before establishing a business relationship, the company must conduct a "Know Your Customer" (KYC) procedure.
• Clients must provide valid documents confirming their identity and address.
• In the case of legal entities, documents on company registration and information on beneficial owners must be provided.

2. Risk Assessment:

• All clients undergo a risk assessment procedure to determine the potential risk level of money laundering.
• Clients are classified into low, medium, and high-risk categories.
• Clients with high-risk levels are subject to more thorough checks and continuous monitoring.

3. Monitoring and Reporting:

• Continuous monitoring of client transactions is conducted to identify suspicious activity.
• All suspicious transactions must be documented and timely reported to the relevant authorities.
• The company keeps records of all reports on suspicious transactions and client checks.

Employee Training and Awareness

1. Training Program:

• All employees, especially those in key positions, undergo mandatory AML training.
• Training is conducted regularly and includes information on new money laundering and terrorism financing methods, as well as updates in legislation.

2. Raising Awareness:

• Regular information sessions are held to raise employee awareness of the importance of AML policy compliance.
• Employees are informed about recognizing suspicious activity and actions to take in such cases.

3. Training Effectiveness Evaluation:

• The effectiveness of the training program is evaluated through regular testing and employee surveys.
• Evaluation results are used to improve and update the training program.

Internal Checks and Audit

1. Planned Checks:

• Internal checks are conducted regularly to assess the effectiveness of AML measures.
• Checks include assessing compliance with policy, procedures, and documentation requirements.

2. Audit:

• Independent internal audits are conducted to verify AML policy compliance and identify potential weaknesses.
• Audit results are presented to the board of directors and used to improve processes and procedures.

3. Reporting:

• The results of checks and audits are documented and stored for the legislatively established period.
• All reports and improvement recommendations are immediately reviewed and implemented by the company's management.

Compliance with Regulatory Requirements

1. Legislative Compliance:

• Perfect Money commits to complying with all applicable laws and regulations of the Union of Comoros and countries where it operates.
• Regular legal consultations and policy updates are conducted to ensure compliance with new requirements.

2. Reporting to Regulatory Authorities:

• All suspicious transactions and activities are immediately reported to the relevant regulatory authorities.
• The company cooperates with law enforcement and regulatory bodies to prevent money laundering and terrorism financing.

3. Interaction with Other Financial Institutions:

• The company cooperates with other financial institutions to exchange information and experience in the AML field when necessary.
• Joint actions and information exchange are aimed at improving methods and procedures for combating money laundering.

Documentation and Record Keeping

1. Record Keeping:

• The company keeps detailed records of all client identification (KYC) procedures, risk assessments, and transaction monitoring.

2. Confidentiality:

• All information collected in the AML policy compliance process is considered confidential and protected from unauthorized access.
• Only authorized employees responsible for AML requirements have access to the information.

3. Electronic Documentation:

• The company uses modern systems for storing and managing electronic documentation.
• All electronic records are protected using current encryption technologies and access control.
• All electronic records are stored with redundancy 2N+1

Conclusion

The AML policy of Perfect Money aims to ensure compliance with legislative requirements, protect the company from risks, and maintain a high level of client and partner trust. All employees must strictly comply with this policy and actively participate in its implementation.